background image

India - Israel Tax Treaty (as amended by 2015 protocol) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 2

Taxes Covered

(1) This Convention shall apply to taxes on income imposed on behalf of a Contracting State or of its political sub-divisions or focal authorities and to taxes on capital imposed on behalf of a Contracting State, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which the Convention shall apply are in particular:

  • (a) In India:
    • (i) the income-tax, including any surcharge thereon; and
    • (ii) the wealth-tax,
  • (hereinafter referred to as "Indian tax");
  • (b) In Israel:
    • (i) the income-tax;
    • (ii) the company tax;
    • (iii) the capital gains tax;
    • (iv) the tax imposed upon gains from the alienation of immovable property according to the Land Appreciation Tax Law; and
    • (v) taxes imposed on real property according to the Property Tax Law,
  • (hereinafter referred to as "Israeli tax").

(4) The Convention shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Convention in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of significant changes which have been made in their respective taxation laws.